NCS000563_NOV_20230913

t F SEAT,
ROY COOPER _
Governor O
ELIZABETH S.BISER
Secretary Y QugM N�
WILLIAM E.TOBY VINSON,JR NORTH CAROLINA
Interim Director Environmental Quality
September 13, 2023
CERTIFIED MAIL 7022 2410 0003 1437 1436
RETURN RECEIPT REQUESTED
Town of Elizabeth City
Attn: Montre D.Freeman,City Manager
Post Office Box 347
Elizabeth City,North Carolina 27907
Subject: NOTICE OF VIOLATION(NOV-2023-PC-0476)
TOWN OF ELIZABETH CITY
NPDES MS4 Permit No.NCS000563
Pasquotank County
Dear Mr.Freeman:
On August 16,2023,staff from the North Carolina Department of Environmental Quality(DEQ) conducted a
compliance audit of the subject National Pollutant Discharge Elimination System(NPDES) Municipal Separate
Storm Sewer System (MS4) Permit. The audit identified major deficiencies with the specific components of
the MS4 permit that were reviewed,as provided in the attached DEQ MS4 Permit Compliance Audit Report.
This report lists the serious deficiencies with certain components of the MS4 permit,which constitutes a
violation of the Clean Water Act and is grounds for enforcement action.
In accordance with Part VI of the permit and DEQ policy,a new 5-year MS4 permit will be issued in response
to the audit. As such,the permittee is required to complete the following actions:
1. Respond in writing within thirty(30)calendar days from the date of receipt of this notice to
acknowledge these requirements and the intent to comply.
2. Adopt a Council Resolution within sixty(60) calendar days from the date of receipt of this notice.
The resolution must declare support for a compliant stormwater management program.A sample
council resolution with the minimum requirements is enclosed with this letter. An original signed
document must be submitted to DEQ.
3. Submit documentation for review and comment within one hundred twenty(120)calendar days
from the date of receipt of this letter:
a. Develop a Draft Stormwater Management Plan(SWMP)which details specific actions,
measurable goals,and implementation timelines to bring the stormwater management
program into compliance with NPDES MS4 requirements over the new 5-year permit term.
The SWMP must be documented utilizing the DEQ Phase II MS4 SWMP Template. The SWMP
must address all known compliance deficiencies including,at a minimum,the items detailed
in the DEQ MS4 Program Audit Report and the self-audit.
4. Submit an NPDES MS4 permit application for whichever comes first:
a. At least one hundred eighty(180) days prior to permit expiration,or
North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 27699-1612
NORT i CAROLMA
Deparcnene of uetroomoerar Wal 919.707.9200

Notice of Violation
Town of Elizabeth City
September 13, 2023
Page 2 of 2
b. Within thirty(30)days of receiving written DEQ concurrence that the submitted SWMP
documents a compliant stormwater management program and the MS4 should submit the
application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit will be
public noticed along with the Draft Final SWMP.
5. Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ approval
and final permit issuance. The final DEQ-approved SWMP shall become an enforceable component of
the NPDES MS4 permit and an Annual Self-Assessment Template that corresponds to the approved
SWMP will be provided.
Required documentation shall be submitted via e-mail to Isaiah.Reedodeq.nc.gov,or to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
2090 U.S.Highway 70
Swannanoa,NC 28778
If the MS4 fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft
SWMP,DEQ may proceed with enforcement. As is stated in Part V,Section A.1(c) of the permit:
Understate law,a daily civil penalty of not more than twenty-five thousand dollars($25,000)per
violation may be assessed against any person who violates or fails to act in accordance with the terms,
conditions,or requirements of a permit[North Carolina General Statute 143-215.6A]. Please note that
compliance with the requirements of this notice and/or issuance of civil or criminal penalties levied by
DEQ does not preclude the EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions,please contact Isaiah Reed at
[phone] or Isaiah.Reed( deq.nc.gov.
Sincerely,
Isaiah Reed,PE,CPS S4CECI
MS4 Program Coordinator
North Carolina Department of Environmental Quality
Enclosures:
DEQ MS4 Permit Compliance Audit Report
Example Council Resolution
EC: Isaiah Reed,MS4 Program Coordinator Isaiah.reed(@deq.nc.gov
Amy Durden, GIS Coordinator adurden(@elizabethcitync.gov
DEMLR NPDES MS4 Permit Laserfiche File

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000563
ELIZABETH CITY, NORTH CAROLINA
410 Pritchard St Elizabeth City NC 27909
Audit Date: August 16, 2023
Report Date: September 6, 2023
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

(This page intentionally left blank)
NCS000563_Elizabeth City MS4 Audit_20230816 i

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation ..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation &Assessment...........................................................................4
Public Education and Outreach.....................................................................................................................7
Public Involvement and Participation ...........................................................................................................8
Illicit Discharge Detection and Elimination (IDDE)........................................................................................9
Post-Construction Site Runoff Controls ......................................................................................................11
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................12
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................14
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................15
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................16
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1............................................17
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000563_Elizabeth City MS4 Audit_20230816 ii

This page intentionally left blank
NCS000563_Elizabeth City MS4 Audit_20230816 iii

Audit Details
Audit ID Number: Audit Date(s):
NCS000563_Elizabeth City MS4 Audit_20230816 August 16,2023
Minimum Control Measures Evaluated:
0 Program Implementation, Documentation&Assessment
0 Public Education&Outreach
0 Public Involvement& Participation
0 Illicit Discharge Detection& Elimination
❑ Construction Site Runoff Controls—No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls—Delegated Sediment and Erosion Control Program
0 Post-Construction Site Runoff Controls
0 Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads(TMDLs)
Field Site Visits:
❑ Municipal Facilities. Number visited:Choose an item.
❑ MS4 Outfalls. Number visited:Choose an item.
❑ Construction Sites. Number visited:Choose an item.
❑ Post-Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: Number visited:Choose an item.
❑ Other: Number visited:Choose an item.
Inspector(s)Conducting Audit
Name,Title Organization
Isaiah Reed, Environmental Engineer NCDEQ
Bill Moore, Environmental Engineer NCDEQ
Varun Prakesh NCDEQ
Audit Report Author:. Date:
Signature G �• 2 U 2
NCS000563—Elizabeth City MS4 Audit_20230816 Page 1 of 17

Permittee Information
MS4 Permittee Name: Permit Effective Date: Permit Expiration Date:
Elizabeth City 2/1/2018 1/31/2023
Mailing Address: Date of Last MS4 Inspection/Audit:
Post Office Box 347 10/16/2013
Co-permittee(s),if applicable: None
Permit Owner of Record: Montre D. Freeman
Primary MS4 Representatives Participating in Audit
Name,Title Organization
Amy Durden,GIS Coordinator COEC
Lashonda Bonsu,Asst to PWD COEC
Randy Lassiter, Project Manager COEC
James McCotter, Street Supervisor COEC
MS4 Receiving Waters
Waterbody Classification Impairments
Pasquotank River SC Not Reviewed
Tiber Creek C;Sw Not Reviewed
Knobbs Creek C;Sw Not Reviewed
Poindexter Creek C;Sw Not Reviewed
Charles Creek C;Sw Not Reviewed
NCS000563_Elizabeth City MS4 Audit_20230816 Page 2 of 17

List of Supporting Documents
Item When Provided
Number Document Title
(Prior to/During/After)
1 2021/2022 Annual Report After
2 Outreach material for public outreach After
3 Screenshot from infrastructure map After
4 IDDE Ordinance After
5 PP&GH written program After
6 Inventory of municipally-owned SCMs. After
7 Inspection report for Privately owned SCM After
8 Applicator License After
9 Sign-in sheet for annual training After
10 0&M Plan for municipally owned SCM After
11 Inventory of municipal facilities After
12 SCM Inspection Report(Municipal) After
NCS000563_Elizabeth City MS4 Audit_20230816 Page 3 of 17

Program Implementation, Documentation & Assessment
Staff Interviewed: Amy Durden,GIS Coordinator
(Name,Title,Role) Lashonda Bonsu,Asst PWD
Randy Lassiter, Project Manager
Permit Citation Program Requirement Status SupportingDoc No.
II.A.1 The permittee maintained adequate funding and staffing to implement and manage
Staffing and the provisions of the Stormwater Plan and meet all requirements of the permit. Yes ---
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
No ---
coordination, implementation,and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
No ---
position(s)assignments provided.
The permittee is current on payment of invoiced administering and compliance Yes BIMS
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Since 2007.$36 per RU,per sqft of impervious surface.No approved SWMP on file.
II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program
Plan components at least annually. Yes SWMPA
Implementation
and Evaluation If yes,the permittee used the results of the evaluation to modify the program Not
components as necessary to accomplish the intent of the Stormwater Program. Applicable ---
Did the permitted MS4 discharges cause or contribute to non-attainment of an Not
applicable water quality standard? Reviewed
If yes, did the permittee expand or better tailor its BMPs accordingly to address Not _
the non-attainment? Applicable
No non-attainment known of.
II.A.3
Keeping the The permittee kept the Stormwater Plan up to date. No ---
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan. No ---
II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the
of the Stormwater Division and the public online. No
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances,or other regulatory mechanisms, providing the legal Partial ---
authority necessary to implement and enforce the requirements of the permit.
Elizabethcitync.gov. Online materials include Ordinance.
Di Notd DEMLR require a modification to the Stormwater Plan? Applicable
71
NCS000563_Elizabeth City MS4 Audit_20230816 Page 4 of 17

Program Implementation, Documentation & Assessment
II.A.3&II.A.S
If yes,did the permittee complete the modifications in accordance with the Not
Stormwater Plan ---
Modifications established deadline? Applicable
II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? No ---
Not
If yes, is there a written agreement in place? Applicable
II.A.7 The permittee maintained written procedures for implementing the six minimum
Written control measures. No ---
Procedures
Written procedures identified specific action steps, schedules, resources and
No ---
responsibilities for implementing the six minimum measures.
Written programs have not been maintained for all MCMs.
Ill A The permittee maintained documentation of all program components including, but
Program not limited to, inspections, maintenance activities, educational programs, Yes ---
Documentation implementation of BMPs,enforcement actions etc.,on file for a period of five years.
111.E The permittee submitted annual reports to the Department within twelve months
Annual Report from the effective date of the permit(See Section III.e.for the annual reporting Yes ---
Submittal period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the Yes BIMS
scheduled date of the first annual report submittal.
The Annual Reports included appropriate information to accurately describe the progress,status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole.This will include information on development and implementation Not
of each major component of the Stormwater Plan for the past year and Reviewed ---
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan.This will include descriptions and supporting information for Not
the proposed changes and how these changes will impact the Stormwater Reviewed
Plan (results, effectiveness, implementation schedule,etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater Not --
Reviewed
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the Not
Reviewed
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections,and enforcement Not
Reviewed
actions.
IV.B
Annual Reporting The Annual Reports document the following:
NCS000563_Elizabeth City MS4 Audit_20230816 Page 5 of 17

Program Implementation, Documentation & Assessment
1. A summary of past year activities, including where applicable,specific Not
quantities achieved and summaries of enforcement actions. Reviewed
2. A description of the effectiveness of each program component. Not
Reviewed
3. Planned activities and changes for the next reporting period,for each Not
program component or activity. Reviewed
4. Fiscal analysis. NotReviewed
NCS000563_Elizabeth City MS4 Audit_20230816 Page 6 of 17

Public Education and Outreach
Staff Interviewed: Amy Durden, GIS Coordinator
(Name,Title,Role) Lashonda Bonsu,Asst PWD
Randy Lassiter, Project Manager
Permit Citation Program Requirement Status Supporting
Doc No.
11.6.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and Partial Website
Objectives
Outreach Program based on community wide issues.
II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and
No ---
Target Pollutants likely sources.
II.B.2.c The permittee identified, assessed annually and updated the description of the target
No ---
Target Audiences audiences likely to have significant storm water impacts and why they were selected.
II.B.2.d Residential The permittee described issues,such as pollutants,the likely sources of those
and Industrial/ pollutants, potential impacts,and the physical attributes of stormwater runoff in No ---
Commercial Issues their education/outreach program.
II.B.2.e
The permittee promoted and maintained an internet web site designed to convey the
Informational No ___
Web Site
program's message.
II.B.2.f
The permittee distributed stormwater educational material to appropriate target
Public Education Partial ---
Materials groups.
Student outreach K-5.
II.B.2.g The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line purpose of public education and outreach. Partial ---
Main line.
II.B.2.h The permittee's outreach program, including those elements implemented locally or
Public Education through a cooperative agreement, included a combination of approaches designed to Yes 2
and Outreach reach the target audiences.
Program
For each media,event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent Partial ---
of exposure.
Additional Maintain website.Truck logo/info.Trashcan information.Stencils.Annual outreach program for schools(K-
Comments: 5)sometimes(K-3).300-400 participants.Customer Service informational table setup in lobby.Outreach to
developers.Setup booth at potato festival.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 7 of 17

Public Involvement and Participation
Staff Interviewed: Amy Durden, GIS Coordinator
(Name,Title,Role) Lashonda Bonsu,Asst PWD
Randy Lassiter, Project Manager
Comments: Public involvement program being developed for next permit cycle.To this point, public involvement has
been limited.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 8 of 17

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: Amy Durden,GIS Coordinator
(Name,Title, Lashonda Bonsu,Asst PWD
Role) Randy Lassiter, Project Manager
James McCotter,Street Supervisor
Permit Citation Program Requirement Status SupportingDoc No.
II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. No ---
If yes,the written program includes provisions for program assessment and Not
evaluation and integrating program. Applicable
The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that Yes 4
II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4.
Legal Authorities If yes,the ordinance applies throughout the corporate limits of the permittee. Not
(Permit Part 1.D] Applicable
I I.D.2.c
The permittee maintained a current map showing major outfalls*and receiving
Storm Sewer Yes 3
streams.
System Map
Map maintained by City GIS
II.D.2.d
The permittee maintained a program for conducting dry weather flow field
Dry Weather Flow No ---
Program
observations in accordance with written procedures.
I I.D.2.e
The permittee maintained written procedures for conducting investigations of
Investigation No ---
Procedures
identified illicit discharges.
II.D.2.f For each case of an illicit discharge or potential illicit discharge,the permittee documented and tracked the
Track and following:
Document
Investigations 1. The dates)the illicit discharge was observed No ---
2. The results of the investigation No ---
3. Any follow-up of the investigation No ---
4. The date the investigation was closed No ---
A tracking system has not been developed which records all necessary information.
II.D.2.e Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into No ---
contact with or otherwise observe an illicit discharge or illicit connection.
II.D.2.h The permittee informed public employees of hazards associated with illegal
Public Education discharges and improper disposal of waste. No
NCS000563_Elizabeth City MS4 Audit_20230816 Page 9 of 17

Illicit Discharge Detection and Elimination (IDDE)
The permittee informed businesses of hazards associated with illegal discharges and
No ---
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
No ---
discharges and improper disposal of waste.
II.D.2.i The permittee promoted, publicized,and facilitated a reporting mechanism for the
Public Reporting public to report illicit discharges. Yes Website
Mechanism
The permittee promoted, publicized,and facilitated a reporting mechanism for staff
Yes Website
to report illicit discharges.
The permittee established and implemented response procedures for citizen
No ---
requests/reports.
II.D.2.1 The permittee implemented a mechanism to track the issuance of notices of violation Not Enforcement and enforcement actions administered by the permittee. Applicable ___
If yes,the mechanism includes the ability to identify chronic violators for Not
initiation of actions to reduce noncompliance. Applicable
No NOVs issued.
Additional IDDE Program will be developed over the next permit cycle to fully meet all program requirements.
Comments:
NCS000563_Elizabeth City MS4 Audit_20230816 Page 10 of 17

Post-Construction Site Runoff Controls
Staff Interviewed: Amy Durden, GIS Coordinator
(Name,Title, Role) Lashonda Bonsu,Asst PWD
Randy Lassiter, Project Manager
James McCotter,Street Supervisor
Comments: Post-Construction program in the City limits of Elizabeth City has been administered by the WARD.As
stated in communication dated January 28,2021, Elizabeth City shall develop and implement a Post-
Construction program.This program shall be developed over the next permit cycle.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 11 of 17

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed: Amy Durden, GIS Coordinator
(Name,Title, Role) Lashonda Bonsu,Asst PWD
Randy Lassiter, Project Manager
James McCotter,Streets Supervisor
Permit Citation Program Requirement Status Supporting
Doc No.
II.G.2.a The permittee maintained a current inventory of facilities and operations owned
Facility Inventory and operated by the permittee with the potential for generating polluted Yes 11
stormwater runoff.
II.G.2.b The permittee maintained and implemented an O&M program for municipally
Operation and owned and operated facilities with the potential for generating polluted Yes 5
Maintenance stormwater runoff.
(O&M)for Facilities
If yes,the O&M program specifies the frequency of inspections. Not
Reviewed
If yes,the C&M program specifies the frequency of routine maintenance Not
requirements. Reviewed If yes,the permittee evaluated the C&M program annually and updated it as Not
necessary. Reviewed ---
O&M Plan contained within in the PP&GH Plan.
II.G.2.c
Spill Response The permittee had written spill response procedures for municipal operations. Yes 5
Procedures
II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted
Roads,and Public stormwater runoff from municipally-owned streets, roads, and public parking Partial ---
Parking Lots lots within its corporate limits annually.
Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs
No ---
based on cost and the estimated quantity of pollutants removed.
II.G.2.f
O&M for Catch The permittee maintained and implemented an O&M program for the
Basins and stormwater sewer system including catch basins and conveyance systems that it No ---
Conveyance owns and maintains.
Systems
II.G.2.g
Inspection and The permittee maintained a schedule of regular inspections of all SCMs owned Yes 12
Maintenance by the permittee.
II.G.2.e
Structural
The permittee maintained a current inventory of municipally-owned or
Stormwater
operated structural stormwater controls installed for compliance with the Yes 6
Controls permittee's post-construction ordinance.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 12 of 17

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.b The permittee maintained and implemented an 0&M program for municipally-
O&M for Structural owned or maintained structural stormwater controls installed for compliance Yes 10
Stormwater with the permittee's post-construction ordinance. If yes,then:
Controls The O&M program specified the frequency of inspections and routine Not
maintenance requirements. Reviewed
The permittee documented inspections of all municipally-owned or Not
maintained structural stormwater controls. Reviewed ---
The permittee inspected all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by Not
Reviewed
permittee.
The permittee maintained all municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by Not ---
Reviewed
permittee.
The permittee documented maintenance of all municipally-owned or Not
maintained structural stormwater controls. Reviewed
Cla
II.G.2.h The permittee ensured municipal employees are properly trained in pesticide,
Pesticide,Herbicide herbicide and fertilizer application management. Yes 8
and Fertilizer
Application The permittee ensured contractors are properly trained in pesticide, herbicide Not
Management and fertilizer application management. Applicable ---
The permittee ensured all permits,certifications,and other measures for Yes 8
applicators are followed.
II.G.2.i The permittee implemented an employee training program for employees
Staff Training involved in implementing pollution prevention and good housekeeping Yes ---
practices.
Annual Training.
II.G.2.i The permittee described and implemented measures that prevent or minimize
Vehicle and contamination of stormwater runoff from all areas used for vehicle and Yes ---
Equipment Cleaning equipment cleaning.
Fire Department does their own vehicle washing.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 13 of 17

Site Visit Evaluation: Municipal Facility No. 1
Facility Name: Date of Site Visit:
Public Works Department August 17, 2023
Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.):
410 Pritchard Street Public Works
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector):
Amy Durden Not reviewed
Name(s)and Title(s)of Facility Representative(s) Present During the Site Visit:
Name Title
James McCotter Streets Supervisor
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan(SWPPP)or similar document?Is it facility-specific?
No.
What type of stormwater training do facility employees receive?How often?
No regular training documented.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
No regular training documented.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No regular process documented.
Does the MS4 inspector's process include taking photos?
No regular process documented.
Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)?
No regular process documented.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
No regular process documented.
Did the MS4 inspector miss any obvious areas of concern?If so,explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
No regular process documented.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)?
Yes. Housekeeping and inspection frequency to be established.
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
To be determined by the permittee.
Notes/Comments/Recommendations
Items discussed on site include secondary containment practices,good-housekeeping practices and proper inspection of concrete
secondary containment structures.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 14 of 17

Site Visit Evaluation: Municipal Facility No. 2
Facility Name: Date of Site Visit:
Elizabeth City WWTP August 17, 2023
Facility Address: Facility Type(Vehicle Maintenance, Landscaping,etc.):
450 Knobbs Creek Drive WWTP
Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(Date and Entity):
Amy Durden Not Reviewed
Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit:
Name Title
Andrew Edwards
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document?Is it facility-specific?
Not requested during site visit.
What type of stormwater training do facility employees receive?How often?
No regular training process documented.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
No regular training process documented.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No regular process documented.
Does the MS4 inspector's process include taking photos?
No regular process documented.
Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)?
No regular process documented.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
No regular process documented.
Did the MS4 inspector miss any obvious areas of concern?If so,explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
No regular process documented.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)?
Yes.See comments below.
If compliance corrective actions were identified,what timeline for correction/follow-up was provided?
To be determined by the permittee.
Notes/Comments/Recommendations
Items discussed include: proper maintenance of grit collection area, proper training for septic pumping companies, proper pollution
prevention and good housekeeping practices in the lime storage and grit collection areas, polymer storage.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 15 of 17

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number: Date and Time of Site Visit:
Number 18 August 17, 2023
Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.):
Herrington Road Not evaluated
Receiving Water: Is Flow Present?If So,Describe(Color,Approximate Flow Rate,
Charles Creek Sheen,Odor, Floatables/Debris,etc.):
Most Recent Outfall Inspection/Screening(Date):
None Occasional pumping down the SCMs nearby
Days Since Last Rainfall: Inches:
Not Reviewed N/A
Name of MS4 Inspector(s)evaluated:
James McCotter,Street Supervisor
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
No regular stormwater training documented.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
No regular process documented.
Does the inspector's process include taking photos?
No regular process documented.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so,what were they?
No.
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests?If so,for what issue(s)?
No.
Will a follow-up outfall inspection be conducted?If so,for what reason?
Yes. Routine.
NCS000563_Elizabeth City MS4 Audit_20230816 Page 16 of 17

Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name: Date of Site Visit:
S MLK Drive SCM August 17, 2023
Site Address: SCM Type:
S. MLK Drive Wet Pond
Most Recent MS4 Inspection(Include Date and Entity):
Not Reviewed
Name of MS4 Inspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date):
James McCotter,Street Supervisor None
Name(s)and Title(s)of Site Representative(s)Present During the Site Visit:
Name Title
None.
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Not requested at the time of the audit.
Does the site have records of annual inspections?Are they performed by a qualified individual?
Yes.Conducted by municipal staff.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive?How often?
No regular stormwater training documented.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes.
Did the MS4 inspector appear knowledgeable about post-construction BMPs(general purpose/function,components,0&M
requirements, etc.)? Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?What format?
Yes.
Does the MS4 inspector's process include taking photos?
No.
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
If needed.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies?If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes.
Compliance/Enforcement
What, if any,enforcement actions(verbal warnings, NOV,etc.)did the inspection result in?
None.
If compliance issues were identified,what timeline for correction/follow-up was provided?
N/A
NCS000563_Elizabeth City MS4 Audit_20230816 Page 17 of 17

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
Resolution No.:###
Date Adopted:###
RESOLUTION AFFIRMING THE MS4NAME COUNCIL'S SUPPORT
REGARDING IMPLEMENTATION OF A COMPLIANT NPDES MS4 STORMWATER PROGRAM
A RESOLUTION to develop and implement a compliant stormwater management program that meets
the requirements of the MS4NAME National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Permit number NCS###to discharge stormwater, inclusive of the
required Stormwater Management Plan to be prepared by the MS4NAME and approved by the North
Carolina Department of Environmental Quality.
WHEREAS,Section 402(p) of the federal Clean Water Act requires NPDES permits for stormwater
discharges from municipal separate storm sewer systems; and
WHEREAS, in North Carolina, NPDES Permits are issued by the North Carolina Department of
Environmental Quality; and
WHEREAS,the North Carolina Department of Environmental Quality issued the MS4NAME its third
NPDES MS4 Permit for discharge of stormwater on DATE; and
WHEREAS,the MS4NAME was issued Notice of Violation number NOV-###-###on DATE for
noncompliance with the issued NPDES MS4 Permit; and
WHEREAS,the MS4NAME acknowledges the specific Notice of Violation requirement to obtain a new
individual NPDES MS4 Permit; and
WHEREAS,the MS4NAME acknowledges the specific Notice of Violation requirement to conduct a self-
audit of permit compliance for the balance of permit requirements not specifically audited by the North
Carolina Department of Environmental Quality, and to develop a draft Stormwater Management Plan to
comply with Section 402(p)(3)(B)(iii) of the Clean Water Act,40 CFR 122.34(b) and NPDES MS4 Permit
requirements, and to submit its draft Stormwater Management Plan to the North Carolina Department
of Environmental Quality no later than 120 Days From NOVDate for review and approval; and
WHEREAS,the MS4NAME acknowledges the specific Notice of Violation requirement to adopt a Council
Resolution to implement a compliant and enforceable stormwater management program as defined by
both the NPDES MS4 Permit number NCS###and the required new Stormwater Management Plan, and
said resolution is to be submitted to the North Carolina Department of Environmental Quality no later
than 60 Days From NOVDate; and
WHEREAS,the MS4NAME acknowledges the requirement to provide adequate funding and staffing to
implement a Stormwater Management Program that complies with its NPDES MS4 Permit and approved
Stormwater Management Plan; and
WHEREAS, the MS4NAME acknowledges that North Carolina Department of Environmental Quality
enforcement action and penalties could result from non-compliance with the specific requirements in
Notice of Violation number NOV-###-###; and

Example Council Resolution of Commitment to Implement a Compliant NPDES MS4 Program
WHEREAS, the MS4NAME acknowledges that any North Carolina Department of Environmental Quality
enforcement action and penalties may not prohibit the U.S. Environmental Protection Agency from
taking its own enforcement action for non-compliance with the issued NPDES MS4 Permit.
NOW,THEREFORE, BE IT RESOLVED that the Council of the MS4NAME hereby affirms its support for
development and implementation of a compliant NPDES MS4 Stormwater Program.
NAME, Mayor NAME, Town Manager
NAME, Stormwater Program Administrator NAME,Town Clerk
ADOPTED BY the City Council of the MS4NAME, North Carolina the day of , 2019 and
signed in authentication thereof the day of 2019.